Safe disposal of non-household pharmaceutical waste

This page will help businesses and institutions (including schools and prisons) to manage and reduce their pharmaceutical waste. Guidelines for properly managing pharmaceutical waste differ depending on where the waste is created, handled and disposed. Some residential health care facilities may qualify as households.

All businesses and institutions that generate pharmaceutical waste are responsible for disposing of that waste according to state and federal law. Given the wide variety of pharmaceutical wastes, complying with those laws can be daunting. The following three resources will help you get started, in addition to the information in the tabs below.

Disposal options

Recommended disposal options

Many facilities have gotten into the habit of flushing unused pharmaceuticals down the toilet because it is convenient, low cost and appears to satisfy state and federal regulations. However, proper disposal is not that simple.

Options for managing and disposing pharmaceuticals depend on what is being disposed, who is creating the waste and who is handling it. In general, the DNR recommends facilities consider the following options.

1. Reuse

Reuse is an option for some drugs. State law allows nursing homes, assisted living facilities and jails to return certain medications to the dispensing pharmacy. Consult your pharmacy to determine whether this is possible for you. In addition, Wisconsin law allows certain pharmacies to take back unit doses of drugs for cancer and chronic diseases.

2. Return

Returning some drugs to the manufacturer is an option for facilities when drugs are eligible for credits or rebates. This is typically done using a "reverse distributor." Waste and waste-like items, however, may not be sent to a reverse distributor.

3. Incineration

Incineration is often the best option, provided it is done properly and is allowed under the incinerator's permit. Hazardous waste incineration must be used for wastes such as chemotherapy waste. Non-hazardous waste such as trace chemotherapy waste, non-hazardous medications and personal care products may go to a medical waste incinerator. Infectious waste may also go to a medical waste incinerator. However, do not mix infectious waste and pharmaceuticals.

4. Landfill

Sending waste to a landfill is legal for health care facilities ONLY when the waste is not a controlled substance, hazardous waste or infectious waste.

Pharmaceuticals DO NOT belong in infectious waste containers

Unless there is a sharp involved, waste pharmaceuticals must be managed separately from infectious waste for four reasons.

Mixing pharmaceutical and infectious waste creates a mixture of wastes which may be difficult and very expensive to manage. If your medical waste company finds hazardous waste in your infectious waste containers, they may refuse to take the mixture. Similarly, your hazardous waste hauler may not accept infectious waste.

There is no guarantee infectious waste will be incinerated. While most infectious waste was incinerated prior to the mid-1990s, most is now disinfected, shredded and landfilled. As noted above, done properly, incineration is the preferred disposal option for pharmaceutical waste.

While some mixing is unavoidable, you should take deliberate steps to minimize these mixtures. If you intend to route pharmaceuticals to an incinerator or other destination, segregate them in their own containers and properly label them.

Transporting pharmaceuticals that are hazardous waste

If you are transporting waste exclusively from a very small quantity generator, you may transport hazardous waste without the use of manifests and without getting a hazardous waste transportation license.

For all other cases, the transporter must have a license and must use manifests.

DNR interpretations on epinephrine disposal

Until recently, all epinephrine wastes, including empty containers, were classified as P042 hazardous wastes when disposed. However, several U.S. Environmental Protection Agency (EPA) regions, states and others requested that EPA clarify whether the P042 listing included epinephrine salts, which are widely used in health care. In October 2007, the EPA issued an interpretation stating that the scope of the P042 listing does not include epinephrine salts.

The DNR has adopted the EPA interpretation with four caveats. DNR's memorandum [PDF] includes a copy of EPA's October 2007 interpretation and reminds generators about best management practices and regulatory obligations that apply to epinephrine salt waste. By adopting this interpretation, DNR's regulation of epinephrine and epinephrine salts is aligned with federal requirements.

In practical terms, this decision means that most health care epinephrine waste is no longer regulated as P042 listed hazardous waste. However, generators still need to:

determine whether each waste is a hazardous waste or not;

determine whether each waste is an infectious waste or not;

check with wastewater authorities to see if each waste may be discarded to the sewer;

correctly determine their generator status; and

report their generator status to DNR if required to do so.

After following the above steps, some health care facilities may find that this regulatory change relieves them of paperwork, training and other hazardous waste requirements.

Lastly, even though this decision may open up other options for disposing of certain epinephrine wastes, the DNR continues to recommend that all waste pharmaceuticals, including non-hazardous epinephrine salt waste, be incinerated.

Legal requirements

Legal requirements for managing waste pharmaceuticals

Non-household pharmaceutical waste may fall under the definition of one or more legal waste categories regulated by the DNR. Examples include hazardous wastes of various kinds, solid waste and infectious waste. Flushing pharmaceuticals may violate hazardous waste and wastewater rules. Non-household pharmaceutical waste may also be subject to requirements of other agencies, such as the federal Drug Enforcement Administration.

Public school nurses should consult the Department of Public Instruction's guidance on disposal of medications. Instructions for using the state contract to manage wastes are in the guidance for managing excess vaccines.

Additional resources

DNR publications related to pharmaceutical waste

Several DNR publications address pharmaceutical disposal. Under the Waste and Material Management Program's searchable publication system, use the "Keyword search" at the top, then choose the keyword "pharmaceuticals" and click "Find." See also publications under the keyword "medical waste" for how to manage medical sharps.